Privacy Policy for the “Boxing Manager” app (Android)
1. Scope
This privacy policy applies only to the Android app “Boxing Manager” (shown under other names in some languages, e.g. “Boxsport Manager”; package name com.zent.boxingmanager), distributed through Google Play. The website fussballmanager-online.net has its own privacy policy.
2. Controller
Zent SoftwareFriedrichstr. 155
10117 Berlin
Germany
Email: info@zent-software.com
This email address is also your contact for all privacy questions. No data protection officer has been appointed.
3. Summary
- The app has no user account and no login.
- We run no server of our own for the app. The app sends no data to us, and we do not include any analytics services of our own (no Firebase, no Google Analytics). Data is processed only by Google for advertising (see section 5).
- Your game progress stays on your device.
- The app shows ads from Google AdMob. Google processes data such as your IP address and advertising ID for this. In the EU/EEA, the United Kingdom and Switzerland, the app asks for your consent first.
- You can change your choice at any time under Preferences → Privacy options. Everywhere else, you can turn off personalized ads via the advertising ID in your Android settings.
- Purchases are handled entirely by Google Play. We do not receive payment details.
4. Data on your device
Game progress and settings
The app stores your game progress, your settings (e.g. sound, music) and your coin balance locally on the device. For purchased coin packs, the app keeps the Google Play purchase token so that each purchase is credited only once. This data is not transmitted to us.
To the extent that we process any of this data at all, the legal basis is Art. 6(1)(b) GDPR (providing the game and crediting purchased coins). Storing it on the device is strictly necessary for the game (Section 25(2) no. 2 of the German TDDDG).
Android backup (Auto Backup)
If you have turned on backup on your device, Android may automatically back up the app’s data to your Google Account (Google Drive) and restore it on a new device. Google performs this backup as the provider of the operating system and of your Google Account. From Android 9 onwards, the backup is end-to-end encrypted if a screen lock is set. We have no access to this backup. You control backup in the Android settings and can manage and delete it there or in Google Drive.
5. Advertising with Google AdMob
To keep the app free, it shows full-screen ads (e.g. after the award ceremony of a fight). For this we use the “Google Mobile Ads SDK (Next-Gen)” from Google AdMob.
Provider
For users in the European Economic Area and Switzerland: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. For all other users: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google processes the data for AdMob as an independent controller (Google Ads Controller-Controller Data Protection Terms), not on our behalf.
What data?
According to Google, the SDK automatically collects and shares with Google:
- IP address, which may be used to estimate the general location of the device,
- user interactions, e.g. app launches, taps and ad views,
- diagnostic data, e.g. app launch time, hang rate and energy usage,
- device and account identifiers: the Android advertising ID, the app set ID and, where applicable, identifiers of signed-in accounts.
The SDK also stores and reads information on your device (local storage, similar to cookies). Google and other advertising partners may use identifiers and IP addresses to serve and measure ads. Data is transmitted encrypted (TLS).
Purposes
Serving ads, personalized ads with your consent; measuring ad performance; analytics; detecting and preventing fraud and abuse. Ad content is limited to the “T” (Teen) rating.
Legal bases
- Consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG): for storing and reading information on your device (e.g. the advertising ID) and for personalized and non-personalized ads, to the extent you agreed in the consent dialog.
- Legitimate interest (Art. 6(1)(f) GDPR): If you do not consent, Google may serve “limited ads”. These do not use the advertising ID for personalization, but use the IP address for delivery and to prevent invalid traffic. Our interest is funding the free app and preventing fraud. You can object to this processing (see Your rights).
Advertising ID
You can reset or delete your advertising ID at any time in the Android settings (depending on the device under “Google” or “Privacy” → “Ads”). Once deleted, the app no longer receives an advertising ID.
More from Google
- How Google uses information from sites or apps that use our services
- Google Privacy Policy
- How Google uses advertising
6. Consent and privacy options (Google UMP)
For consent we use Google’s “User Messaging Platform” (UMP). In the EU/EEA, the United Kingdom and Switzerland, a dialog appears on first launch. There you can consent, manage options (individual purposes and partners) or not consent. The dialog lists all advertising partners that may receive data. The game works fully in every case, including without consent.
The Preferences → Privacy options button appears wherever such a choice is provided: in the EU/EEA, the United Kingdom, Switzerland and US states with their own privacy laws (see section 14).
Your choice is stored on the device (in the format of the IAB Transparency & Consent Framework). To find out whether the dialog is needed, UMP fetches information from Google servers at launch; your IP address is transmitted in the process.
Withdrawal and changes: You can withdraw or change your consent at any time with effect for the future under Preferences → Privacy options in the app. This does not affect the lawfulness of processing carried out before the withdrawal.
The legal basis for storing your choice is Art. 6(1)(c) in conjunction with Art. 7(1) GDPR (proof of consent) and Section 25(2) no. 2 TDDDG.
7. In-app purchases (Google Play Billing)
You buy coin packs through Google Play’s billing system. Payment and your payment details are processed solely by Google under the Google Play terms and the Google Payments Privacy Notice. The app only receives the product ID, purchase state and purchase token. It stores the token locally so that a purchase is not credited twice, and sends none of this to us. The legal basis is Art. 6(1)(b) GDPR.
8. Recipients
Data is received only by Google (AdMob, UMP, Google Play) and by Google’s advertising partners listed in the consent dialog under “Manage options”. We ourselves receive no personal data from the app. Whether sharing data with Google counts as a “sale” under US law is explained in section 14.
9. Transfers to third countries
Google also processes data in the USA and other countries outside the EU. Google LLC is certified under the EU-U.S. Data Privacy Framework (including the UK Extension and the Swiss-U.S. framework). Transfers to the USA are therefore covered by the European Commission’s adequacy decision of 10 July 2023 (Art. 45 GDPR). Where this does not apply, Google uses the European Commission’s standard contractual clauses (Art. 46 GDPR). Details: Google Ads data transfers.
10. Retention
- Game progress, settings and purchase tokens: until you uninstall the app or clear its data in the Android settings.
- Your consent choice: until you withdraw or change it, or until the app asks you again.
- Backup in your Google Account: according to the settings of your device and Google Account.
- Data held by Google: according to Google’s retention periods (see the Google Privacy Policy).
11. Security
The Google libraries included in the app transmit data encrypted (TLS). The app itself transmits no data to us. From Android 9 onwards, the Android backup is end-to-end encrypted if a screen lock is set.
12. Your rights
Under the GDPR you have the right to
- access (Art. 15), rectification (Art. 16), erasure (Art. 17) and restriction of processing (Art. 18),
- data portability (Art. 20),
- object to processing based on legitimate interests (Art. 21), e.g. to limited ads,
- withdraw consent with effect for the future (Art. 7(3)), most easily via Preferences → Privacy options,
- lodge a complaint with a data protection supervisory authority (Art. 77), in particular in the member state of your habitual residence, place of work or the place of the alleged infringement.
To exercise these rights, contact the email address above. Please note: we do not hold any data from the app that we could link to you. Requests about advertising data are most effectively sent directly to Google, e.g. via the Google Privacy Policy.
You are under no legal or contractual obligation to provide data. Without the technically necessary data (e.g. the IP address), however, Google cannot serve ads.
13. Deleting data
- Game progress and local data: uninstall the app, or choose “Storage → Clear data” for the app in the Android settings.
- Advertising ID: reset or delete it in the Android settings (see section 5).
- Consent: withdraw it under Preferences → Privacy options.
- Backup: delete it in Google Drive or in the Android settings under “Backup”.
- Data held by Google: via the controls and contact options in the Google Privacy Policy.
14. Notice for users in the USA (US state privacy laws)
To the extent that US state privacy laws (e.g. California, CCPA/CPRA) apply to us, the following also applies:
- Categories of data processed through the app: identifiers (advertising ID, app set ID, IP address), internet and network activity (interactions with the app and the ads), approximate geolocation (derived from the IP address) and inferences drawn by Google for advertising purposes.
- Purposes: advertising, measurement, analytics, fraud prevention (see section 5).
- “Sale” or “sharing”: Making this data available to Google and its advertising partners for personalized advertising may count as a “sale” or “sharing” (cross-context behavioral advertising) under these laws.
- Opt-out (“Do Not Sell or Share My Personal Information”): You can opt out under Preferences → Privacy options. Google will then process your data only in a restricted way (Restricted Data Processing).
- Your rights: to know/access, delete, correct, opt out, and not to be discriminated against for exercising your rights. Send requests to the email address above.
- Minors: The app does not ask for your age. If you are under 16, we recommend opting out of sale and sharing under Preferences → Privacy options.
15. Children and teenagers
The app is intended for users aged 13 and over. We do not knowingly collect data from children under 13.
For users under 16 in the EEA: In many countries (e.g. Germany), teenagers under 16 cannot consent on their own to the processing of their data for advertising; in some countries the age limit is between 13 and 16. If you are younger, please consent in the consent dialog only with your parents’ permission, or choose “Do not consent”. You can change your choice at any time under Preferences → Privacy options.
16. Automated decision-making and profiling
We do not make any automated decisions within the meaning of Art. 22 GDPR. Google may build profiles to personalize ads; in the EU/EEA, the United Kingdom and Switzerland only with your consent.
17. Changes
We update this privacy policy when the app or the law changes. The version published here applies; its date is shown at the top. This policy is available in English and in German.